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to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, 332 F.3d at 980. The same is no less true in the plea negotiation context. The free availability in discovery to civil plaintiffs of communications
riminately compel a taxpayer to disclose this information merely because he has become a party to a lawsuit would undermine this policy"); see also Premium Service Corp. v. Sperry & Hutchinson Co., 511 F.2d 225, 229 (9th Cir. l 975)(would have been appropriate for district court to quash subpoena for tax returns base
to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, 332 F.3d at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiation
riminately compel a taxpayer to disclose this information merely because he has become a party to a lawsuit would undermine this policy"); see also Premium Service Corp. v. Sperry & Hutchinson Co., 511 F.2d 225, 229 (9th Cir. 1975)(would have been appropriate for district court to quash subpoena for tax returns based
to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, 332 F.3d at 980. The same is no less true in the plea negotiation context. The free availability in discovery to civil plaintiffs of communications
scriminately compel a taxpayer to disclose this information merely because he has become a party to a lawsuit would undermine this policy"); w also Premium Service Corp. v. Sperry & Hutchinson Co., 511 F.2d 225, 229 (9th Cir. 1975Xwould have been appropriate for district court to quash subpoena for tax returns based
Entities connected to both Goodyear Tire and Premium Service Corp.

Jeffrey Epstein
PERSONJane Doe
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ORGANIZATIONJack Goldberger
PERSONMaria Farmer
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ORGANIZATIONSperry & Hutchinson Co.
ORGANIZATIONMermelstein & Horowitz
ORGANIZATIONRobert C. Josefsberg
PERSONKatherine W. Ezell
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